As recently reported by the Austrian Ministry of Finance, the competent authorities of Austria and the USA have concluded an agreement on the exchange of country-by-country reports.
Pursuant thereto, the competent authorities shall exchange annually and automatically the country-by-country (CbC) reports received from reporting entities if, on the basis of the information provided in a CbC report, one or more constituent entities of a multinational enterprise (MNE) are tax resident or have a permanent establishment in the respective other state.
CbC reports shall be first exchanged with respect to fiscal years of MNE groups commencing on or after 1 January 2016. The exchange shall generally be effected as soon as possible, but no later than 18 months after the last day of the fiscal year of the MNE group. For example, in respect of fiscal years ending on 31 December 2018, a CbC report shall be exchanged by 30 June 2020 at the latest.
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